Be Prepared! The motto of the Boy Scouts of America has never been as true for many Nursing Home Administrators as it has during the recent events of the nursing home tragedies that have occurred in Texas and Florida during Hurricanes Harvey and Irma. For many nursing home Administrators, being prepared for an emergency, or disruptive event, is the ultimate responsibility; a high priority. The CMS final rules of participation on Emergency Preparedness which takes effect on November 15, 2017 will only add another layer of regulations to an already heavily regulated environment for the Administrator.

One certainty that will face all Nursing Home Administrators (in the wake of Florida) will be that the CMS and State surveyors will be reviewing (in detail) a facility’s emergency plan, and in some cases “ripping” it to shreds. How can Administrators be sure that the emergency plan they have will meet requirements? Until we begin to see how deficiencies will be cited by surveyors, this question remains to be answered. Regardless of outcomes, the Administrator must have an emergency plan and documented exercises that have tested the plan.

Today, the Centers for Medicare & Medicaid Services (CMS) finalized rules to establish consistent emergency preparedness requirements for health care providers participating in Medicare and Medicaid, increase patient safety during emergencies, and establish a more coordinated response to natural and man-made disasters. These new rules will require certain participating providers and suppliers to plan for disasters and coordinate with federal, state, tribal, regional, and local emergency preparedness systems to ensure that facilities are adequately prepared to meet the needs of their patients during disasters and emergency situations. The effective date will be November 16, 2016 and the implementation date will be November 16, 2017. [emphasis added]